DTT EPS comment letter final 5 Dec 08

Deloitte Touche Tohmatsu 2 New Street Square London EC4A 3BZ United Kingdom Tel: +44 20 7007 0907 Fax: +44 20 7007 0158 www.deloitte.com www.iasplus.com 5 December 2008 Sir David Tweedie, Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Re: Exposure Draft, Simplifying Earnings per Share - proposed amendments to IAS 33 Dear Sir David, Deloitte Touche Tohmatsu is pleased to respond to the exposure draft, Simplifying Earnings per Share, proposed amendment to IAS 33 (the “proposed amendment” or the “Exposure Draft”). As indicated in previous comment letters, we support global convergence around high-quality accounting standards. Therefore, we continue to support the efforts of the IASB to work closely with the Financial Accounting Standards Board (FASB) and national standard setters to develop high quality standards that will be applied globally. We encourage the FASB and the IASB to work together to develop converged accounting standards that use the same words when describing the same accounting principles or guidance and organise those principles or guidance in the same or similar manner. By doing so, we believe the risk the accounting standards will be interpreted differently will be reduced, if not eliminated. We appreciate the efforts made to converge the two earnings per share (EPS) standards, but note that the look of the standards and words differ in instances when the intended ...